78/August 2015

Transcription

78/August 2015

New England Interstate
Water Pollution Control
Commission
Bulletin 78
August
2015
Wannalancit Mills
650 Suffolk Street, Suite 410
Lowell, MA 01854-3694
www.neiwpcc.org/lustline
L.U.S.T.LINE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Ta-da!
Meet the 2015 Revised UST Regulation
Carolyn Hoskinson
Inside
A
t long last, USEPA has issued the 2015 underground storage tank (UST) regulation (www.epa.gov/oust/fedlaws/revregs.html). The regulation is available in the
July 15, 2015 Federal Register. After many years of work and
collaboration with stakeholders, this regulation is final—and I
am happy I can now say that. I think the old English proverb
“Good things come to those who wait” applies here. And these
changes are definitely good for the environment.
■ continued on page 2
5
6
7
11
12
13
New OUST PVI Guide
First Impressions on New UST Rule
Why Inventory Can’t Find Leaks in Satellite Piping
UST Insurance Scam in Michigan
How to Know That an FR Document Is Real
15
Iowa’s Corrective Action Conferences
Nuggets of Time
18
Getting a Leak Detection Device on NWGLDE Website
LUSTLine Bulletin 78 • August 2015
■ Revised
from page 1
UST Regulation
As you can imagine, we feel a
great sense of accomplishment. Of
course, we are well aware that this
is only the beginning. Implementation is next, and that means significant work ahead for USEPA, state
and territorial UST programs, tribal
UST programs, owners and operators, equipment manufacturers, vendors, and others. Our next steps to
implement the 2015 UST regulation
will result in greater protection for
human health and the environment;
these changes are designed to further
reduce the number of releases to the
environment and help ensure earlier
detection of releases, if they occur.
Why Did USEPA Revise the
1988 UST Regulation?
As you know, the 1988 UST regulation guided us in preventing releases,
detecting releases, and cleaning up
those that occurred. This original
regulation was an excellent start for
setting minimum standards for UST
systems and protecting groundwater.
L.U.S.T.Line
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Jaclyn Harrison, NEIWPCC Project Officer
Erin Knighton, USEPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commission (NEIWPCC). It is produced through
cooperative agreements (US-83555901 and
US-83556001) between NEIWPCC and the
U.S. EnvironmentalProtection Agency.
LUSTLine is issued as a communication
service for the Subtitle I RCRA
Hazardous & Solid Waste Amendments
rule promulgation process.
LUSTLine is produced to promote
information exchange on UST/LUST issues.
The opinions and information stated herein
are those of the authors and do not necessarily reflect the opinions of NEIWPCC.
This publication may be copied.
Please give credit to NEIWPCC.
NEIWPCC was established by an Act of
Congress in 1947 and remains the oldest agency in the Northeast United States
concerned with coordination of the multimedia environmental activities
of the states of Connecticut, Maine,
Massachusetts, New Hampshire,
New York, Rhode Island, and Vermont.
NEIWPCC
Wannalancit Mills
Lowell, MA 01854
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
LUSTLine is printed on recycled paper.
2
Carolyn Hoskinson Director, USEPA’s Office of
Underground Storage Tanks
The 1988 regulation required
owners and operators to have
spill, overfill, and release
detection equipment in place
for their UST systems, but it
did not address operation and
maintenance of that equipment.
In addition, the 1988 regulation
was based on technologies that
are now more than 25 years old
and deferred some UST systems
because release detection was
not readily available for those
systems decades ago.
The Energy Policy Act of 2005
included key requirements, such
as secondary containment and
operator training, for states and
territories that receive Leaking
Underground Storage Tank
Trust Fund money. However,
those requirements did not
apply in Indian country, leaving
an inequity in environmental
protection in Indian country.
These factors contributed to our
decision to update the federal
UST requirements, which will
apply in Indian country as well.
But in the 25 plus years since USEPA
established that regulation, much
has changed. We gained significant
experience from addressing tank
systems, we saw improved technologies for tank systems, and we have
a greater awareness of the need for
proper operation an d maintenance.
Many states had already recognized
these issues and implemented more
stringent requirements.
The 1988 regulation required
owners and operators to have spill,
overfill, and release detection equipment in place for their UST systems,
but it did not address operation and
maintenance of that equipment. In
addition, the 1988 regulation was
based on technologies that are now
more than 25 years old and deferred
some UST systems because release
detection was not readily available
for those systems decades ago.
included key requirements, such as
secondary containment and operator training, for states and territories
that receive Leaking Underground
Storage Tank Trust Fund money.
However, those requirements did not
apply in Indian country, leaving an
inequity in environmental protection
in Indian country.
These factors contributed to our
decision to update the federal UST
requirements, which will apply in
Indian country as well.
What Are the Major Changes
in the 2015 UST Regulation?
The 2015 UST regulation will help
prevent and detect UST releases,
which are one of the leading sources
of groundwater contamination.
When the changes are implemented,
people’s health and our country’s
environment will be better protected
from UST releases.
The regulation requires that
UST equipment is operated and
maintained properly; acknowledges
improvements in technology over the
past 25 plus years by including newer
technologies and adding requirements to detect releases from UST
systems deferred in the 1988 regulation; and adds requirements for UST
secondary containment and operator
training.
Because states and territories
are the primary implementers of the
UST program, and in some instances,
their requirements are more stringent
August 2015 • LUSTLine Bulletin 78
than the federal UST regulation, UST
owners and operators in some states
may already meet many of the 2015
UST requirements. For other states
and in Indian country, these changes
will set more protective standards
to prevent and detect releases more
quickly, and this will limit impacts to
vital groundwater resources.
In particular, the 2015 UST regulation revises 40 CFR part 280 by:
n Adding federal requirements for
operator training. The Energy
Policy Act of 2005 required
operator training, and most
states require operator training.
Now, however, this is a requirement for USTs in Indian country
and those states not previously
requiring it. Operator training
is a way to educate UST system
operators and help them better
prevent releases by complying
with requirements.
n Adding federal requirements for
secondary containment for new
and replaced tanks and piping.
required secondary containment,
and most states require secondary containment. However,
the 2015 UST regulation now
requires it for USTs in Indian
country and those states not previously requiring it. Secondary
containment will reduce releases
to the environment by containing them in secondary areas and
detecting them before they reach
the environment.
n Establishing additional requirements for operation and
maintenance of UST system
equipment. These new require-
ments include walkthrough
inspections, spill prevention
equipment testing, overfill prevention equipment inspections,
testing for containment sumps
used for piping interstitial monitoring, and release detection
equipment testing.
Although appropriate UST system equipment is essentially in
place, we realized the need to
ensure owners and operators
properly operate and maintain
their equipment. These additional requirements highlight
the importance of operating and
maintaining UST equipment so
The 2015 UST regulation will
help prevent and detect UST
releases, which are one of the
leading sources of groundwater
contamination. When the changes
are implemented, people’s health
and our country’s environment
will be better protected
from UST releases.
The 2015 UST regulation requires
that UST equipment is operated
and maintained properly;
acknowledges improvements
in technology over the past
25 plus years by including
newer technologies and adding
requirements to detect releases
from UST systems deferred in
the 1988 regulation; and adds
requirements for UST
secondary containment and
operator training.
Because states and territories
are the primary implementers of
the UST program, and in some
instances, their requirements are
more stringent than the federal
UST regulations, UST owners and
operators in some states may
already meet many of the 2015
UST requirements. For other
states and in Indian country,
these changes will set more
protective standards to prevent
and detect releases more quickly,
and this will limit impacts to vital
groundwater resources.
releases to the environment are
prevented or quickly detected.
n Requiring owners and operators of UST systems storing fuel
for use by emergency power
generators to perform release
detection. USEPA removed the
deferral and, within three years,
requires owners and operators to
begin performing release detection. These UST systems must
already meet all other parts of
the UST regulation.
n Requiring that airport hydrant
systems and field-constructed
tanks meet requirements under
the new subpart K. In the 1988
UST regulation, USEPA deferred
some USTs from most requirements, but we always intended
to look at them again. Our analy
sis showed it is now appropriate to include those tanks in the
federally regulated universe.
Because of their unique nature,
how they function, and their
design, we tailored the regulatory requirements for airport
hydrant systems and field-constructed tanks and consolidated
them in one location, subpart K,
of the 2015 UST regulation.
n Partially excluding wastewater
treatment tank systems, UST
systems containing radioactive material, and UST systems
that are part of emergency
generator systems at nuclear
power generation facilities,
which were deferred in the 1988
UST regulation. USEPA partially
excluded these tanks from most
of the UST regulation, but we
continue to maintain installation
requirements and require release
response and corrective action
for these UST systems.
n Defining compatibility of emerging fuels and determining how
owners demonstrate compatibility. Section 280.32 of the 1988
UST regulation required that
UST systems be compatible with
the substances stored in them.
Given the increased use of new
and emerging fuels, such as biofuels and biodiesel, we thought
it important to continue emphasizing new fuels and their compatibility with the systems in
which they are stored.
n Updating codes of practice. This
adds newer codes of practice,
updates titles of codes of practice, and removes codes of practice that are not applicable or no
longer exist.
3
■ Revised
from page 3
UST Regulation
n Making editorial and technical
corrections. This corrects spelling, numbering, and other editorial errors.
How Are UST Owners and
Operators Affected by
Changes in the 2015 UST
Regulation?
The changes in the 2015 UST regulation affect both small and large UST
owners and operators, including
owners and operators of USTs on
tribal lands. The location of owners’
and operators’ UST systems, such as
whether the systems are in Indian
country, states with state program
approval (SPA), or non-SPA states,
determines when and how the 2015
UST regulation affects them. That
means a subset of the 570,000 federally regulated USTs in the United
States will immediately be subject to
the 2015 UST regulation.
UST Owners and Operators in
Indian Country
Owners and operators of UST systems in Indian country must comply with all 2015 UST requirements;
this now includes operator training
and secondary containment requirements, which did not previously
apply in Indian country. The 2015
UST regulation fulfills objectives in
USEPA’s August 2006 UST Tribal
Strategy, where both USEPA and
tribes recognized the importance
of requirements that ensure parity
in program implementation among
states and in Indian country.
UST Owners and Operators In SPA
States and Territories
As of June 2015, 38 states as well as
the District of Columbia and Puerto
Rico have state program approval.
Under SPA, state programs operate
in lieu of the federal UST program.
Owners and operators with UST
systems in SPA states must continue
to follow their state or territorial
requirements. Those requirements
remain in place until a state revises
its requirements to meet the 2015 federal UST regulation. That means the
2015 UST regulation does not affect
UST owners and operators in SPA
states until those states either revise
their UST requirements or their SPA
status changes.
4
UST Owners and Operators in
Non-SPA States and Territories
UST owners and operators in the
remaining 16 non-SPA states and
territories must meet both the 2015
UST requirements and their states’
requirements. That means the 2015
UST regulation affects these nonSPA state owners and operators. In
addition, owners and operators in
those states must follow their states’
UST requirements.
The changes in the 2015 UST
regulation affect owners and operators whose UST systems were partially deferred, such as airport
hydrant systems, field-constructed
tanks, or UST systems storing fuel
solely for use by emergency power
generators, in the 1988 UST regulation.
Owners and Operators of Airport
Hydrant Systems and FieldConstructed Tanks
The U.S. Department of Defense is
one of the primary owners of airport hydrant systems and fieldconstructed tanks. Previously, the
1988 UST regulation required that
airport hydrant systems and fieldconstructed tanks meet the interim
prohibition requirements of subpart
A (corrosion protected, made of noncorrodible materials, or otherwise
designed and constructed to prevent
releases during the operating life of
the facility due to corrosion or structural failure) and release response
and corrective action requirements
of subpart F. Because of the unique
nature of airport hydrant systems and field-constructed tanks
and because they function and are
designed differently than conventional USTs, we consolidated the regulatory requirements for these two
categories in one location, subpart K,
of the 2015 UST regulation. We think
that owners and operators of airport
hydrant systems are currently performing many of the requirements in
the 2015 UST regulation and will only
need to make minor modifications to
their current practices.
Owners and Operators of UST
Systems with Emergency Power
Generators
Approximately 20 states currently
require release detection for UST
systems storing fuel solely for use
by emergency power generators.
USEPA deferred these systems
from release detection in the 1988
UST regulation. Per the 2015 UST
regulation, UST systems for use by
emergency power generators must
have release detection and secondary containment and use interstitial
monitoring. We think the majority
of federally owned emergency generator tanks already meet the release
detection requirement.
How Are State and Territorial
UST Programs Affected by
the SPA Requirements?
State and Territorial UST
Programs with SPA
The changes may require some
state and territorial UST programs
to modify their existing requirements, make them consistent with
and at least as stringent as the 2015
UST regulation, and then reapply
for state program approval. The
38 SPA states as well as the District
of Columbia and Puerto Rico have
three years to reapply for state program approval.
State and Territorial UST
Programs without SPA
For the remaining 16 states and
territories without state program
approval, the 2015 UST regulation
applies to UST system owners and
operators. If in the future these states
and territories want to obtain SPA,
they may need to adjust their existing state regulations.
How Did We Determine
Which Areas to Change?
Over the past three decades,
USEPA’s guiding principle in running the national UST program
has been one of inclusion. We have
always looked to you, our partners,
for your thoughtful input and valuable expertise. So when it came time
to figure out which areas of the 1988
UST regulation to change, we naturally reached out to a wide variety of
stakeholders.
We elicited input and considered
ideas from states, tribes, owners and
operators, equipment manufacturers, environmentalists, and community groups. Your input helped
us determine potential areas for
change. And after extensive stakeholder outreach, we compiled a list
of proposed changes that would
most appropriately address gaps in
We are extremely excited about
these program-altering changes,
which strengthen UST prevention
and detection practices, increase
emphasis on properly operating
and maintaining UST equipment,
and ensure parity in implementing
the national UST program. The
2015 UST regulation will allow
us to better prevent and detect
releases from UST systems.
Because of this regulation,
environment will be better
protected from UST releases.
the 1988 UST regulation and consider the latest technology.
We published proposed regulations in 2011 and accepted public
comments over a five-month public
comment period. After carefully analyzing all the comments, we developed the 2015 UST regulation, which
USEPA published in the July 15, 2015
Federal Register.
Next Steps and What Do We
Need from States, Owners,
Industry, Others?
We now move to the implementation
phase for the 2015 UST regulation.
We are reaching out to our stakeholders and spreading the word;
developing training and plain language documents to foster implementation; and enlisting the help of
our partners to successfully implement the 2015 UST regulations.
We are extremely excited about
these program-altering changes,
which strengthen UST prevention
and detection practices, increase
emphasis on properly operating and
maintaining UST equipment, and
ensure parity in implementing the
national UST program. The 2015 UST
regulation will allow us to better prevent and detect releases from UST
systems. Because of this regulation,
environment will be better protected
from UST releases.
For more on the 2015 UST regulation, see USEPA’s website, website,
www.epa.gov/oust. ■
Want to hear about what USEPA is doing to protect,
preserve, and clean up our land?
Follow @EPAland on Twitter. In addition to other subjects, you
will also see some tweets about underground storage tanks.
At Last!
OUST’s Petroleum Vapor
Intrusion Guide
T
he USEPA’s guide for addressing petroleum vapor intrusion (PVI), Technical Guide For
Addressing Petroleum Vapor Intrusion
At Leaking Underground Storage Tank
Sites, EPA 510-R-15-001, is now available on the agency’s website, www.
epa.gov/oust/cat/pvi/. A USEPA Office
of Underground Storage Tanks
(OUST)-led workgroup developed
the guide as a collaborative effort
over a period of years, beginning in
2009. The project was initiated at the
request of partners and stakeholders
who felt that national guidance was
needed to ensure vapor intrusion
would be adequately considered and
addressed at LUST sites. In addition
to the input from the workgroup,
OUST received helpful input during
the 2013 public review period and
2014 interagency review.
The guidance will also help
regulators, consultants, and other
stakeholders avoid misinterpreting
the potential for vapor intrusion and
performing unnecessary investigations. Helping better target resources
is critical given that more than 70,000
LUST sites are in the “cleanup pipeline.” This technical guide is a companion to the USEPA Office of Solid
Waste and Emergency Response’s
(OSWER’s) more general vapor
intrusion guide (see www.epa.gov/
oswer/vaporintrusion/). Together, these
two documents replace the 2002
draft vapor intrusion guide.
The PVI Guide
The PVI guide focuses on releases of
PHCs from USTs regulated under 40
CFR part 280. It takes the aerobic bio-
degradation of PHCs into account
and provides screening criteria
based on physical separation distances between vapor sources and
potential receptors. The screening
criteria were derived by analyzing a
large data set of samples from leaking UST sites. The PVI guide applies
to new and existing releases of PHCs
and non-PHC fuel additives from
leaking USTs, as well as previously
closed sites where the implementing
agency has reason to suspect there
may be a potential for PVI. Although
USEPA developed the guide based
on data from typical UST sites, it
may also be helpful when addressing PHC contamination at compar
able non-UST sites.
OSWER’s More General VI Guide
The more general OSWER vapor
intrusion guide addresses a wide
variety of sites and a broader
range of contaminants. It includes
non-petroleum sites, as well as
comingled plumes of petroleum and
chlorinated solvents and petroleum
contamination at sites that are not
comparable to UST sites (e.g., refineries).
What Now?
OUST is planning to host a webinar
about the PVI guide. Also, USEPA’s
Office of Research and Development
(ORD) has developed several technical documents supporting the PVI
guide (see www.epa.gov/oust/cat/pvi/).
If you have questions, contact Hal
White at white.hal@epa.gov. ■
5
Field Notes ✍
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
First Impressions on USEPA’S New UST Rule
Now that the U.S. Environmental Protection Agency’s (USEPA’s) first major update to its 1988 underground storage tank
(UST) rule has been finalized, we’ll be getting reactions from various corners of the UST-related world—regulators, tank
owners/operators, equipment manufacturers, and service companies. So here’s my initial take after listening to scores of tank
owners/operators, equipment manufacturers, and service companies.
n PEI Recommended Practices. USEPA reviewed
information from more than 25 code-making groups
on more than 200 codes of practice that have been
developed or revised since the 1988 UST regulation. USEPA reviewed PEI’s Recommended Practice
for Testing and Verification of Spill, Overfill, Leak Detection and Spill Containment (PEI/RP1200) and in the
2015 regulation included it in areas where testing
or inspection is required. The agency also reviewed
and included PEI’s Recommended Practice for the
Inspection and Maintenance of UST Systems (PEI/
RP900) in the walkthrough inspections portion of
the 2015 regulation.
The warnings about the use of vent-restriction
devices contained in Section 7.3.3 of PEI’s Recommended Practices for Installation of Underground
Liquid Storage Systems (PEI/RP100-11) were instrumental in USEPA’s decision to no longer allow the
use of flow restrictors for new UST system installations and when overfill prevention equipment is
replaced.
Including these documents in the federal rule is a
credit to the dozens of men and women representing the equipment, UST owner/operators, and regulatory communities who unselfishly shared their
time and knowledge to produce useful and widely
accepted recommended practices. Thanks for all of
you who participated in the process.
All of PEI’s recommended practices are reviewed
and updated on a regular basis. The committee
responsible for writing PEI/RP900 elected to wait
until the final rule was published before updating
their recommended practice. Now that the regulation is out, I expect work on the second edition
of RP900 to begin this November. Look for both
RP1200 and RP100 to be revised and available
sometime during the first half of 2016.
n Stakeholder Outreach. UST technology has
changed a great deal since the 1980s and the update
to the regulation will help bring us up to date.
USEPA’s stakeholder outreach before publishing the 2011 proposed regulation was extensive. I
know that because I attended all of the public meetings leading up to the publication of the proposed
6
r egulation. Furthermore, USEPA continued to meet
with all interested stakeholders during and after the
five-month comment period. The final rule demonstrates that USEPA sought input from the regulated
community.
n Periodic Testing of Secondary-Containment Tanks
and Piping. To date, USEPA’s decision not to require
the testing of these UST systems has raised the
most eyebrows among PEI contractor members.
PEI members almost unanimously agree that their
tank-owner customers did not want to test secondarily contained tanks and piping because of the cost
involved. They get that, and understand why USEPA
made the decision they did given the comments in
opposition to such a requirement in the original proposal. But PEI members don’t believe that testing
those systems creates a disincentive for owners and
operators who care about keeping petroleum out of
the ground and water from upgrading their systems
with secondary containment.
n Fair and Balanced. It is obvious that USEPA carefully considered all of the comments submitted during the public comment period, including concerns
regarding potential costs to small businesses, and
worked to minimize those costs by making certain
changes to the final UST regulation. No group got
everything they wanted—they never do—but every
tank owner association representative I have talked
with so far says they can live with the final rule. In
full disclosure, I did not talk with any implementing
agency before I wrote this column. I figure they are
too busy trying to determine what the rule means to
their program.
n Prognosticating. I read all of the comments submitted to USEPA on the proposed regulation that ended
April 16, 2012. After analyzing those comments, I
wrote an article for the Third Quarter 2012 PEI Journal where I drew my own conclusions about what
changes might or might not be reflected in the final
regulations. Bottom line: I got 72 percent correct.
That would equate to an unheard of batting average
in baseball or result in a once-in-a lifetime field goal
percentage in basketball, but if we were in school
I would be average at best. I plan to do better next
time. ■
Tank
– nically Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature of LUSTLine.
As always, we welcome your comments
and questions. If there are technical
issues that you would like to have
Marcel discuss, let him know at
marcel.moreau@juno.com.
Of Saws, Hammers, and Leak Detection
Why Inventory Can’t Find Leaks in Satellite Piping
T
he preamble to the federal rule, published over a quarter century ago, stated that all the methods of leak detection described in the
rule, “appear to be successfully detecting releases when properly applied.”1 The USEPA’s position at the time was that all leak
detection methods included in the federal rule would work equally well if the guidelines presented in the rules were followed.
Policy versus Science
While equality among leak detection methods may be politically correct from a rule-writing perspective,
it is not scientifically correct from a
physics perspective. For example,
groundwater monitoring is founded
on vastly different principles than
automatic tank gauging. A tanktightness test is worlds away from
inventory control as a leak detection method. The actual mechanics
of how leak detection methods work
require that different methods have
different abilities to detect different
types of leaks. Although any of the
leak detection methods described
in the federal rule may be used to
comply with the regulations (assuming all the guidelines in the regulations are followed), the magnitude
and locations of the leaks that can be
detected by these different methods
vary greatly. This was brought home to me by
a recent query from a regulator who
wondered why line-leak detectors
could be used for leak detection on
the satellite piping that runs between
the master and the satellite dispenser
at a truck stop but statistical inventory reconciliation (SIR) could not.
As I thought about my answer, I realized that part of the regulator’s issue
was taking the regulatory philosophy that all leak detection methods
are effective a bit too literally, combined with an understanding of the
workings of various leak detection
methods that was a bit too shallow.
Why I’m Writing this Article
I have two goals in writing this article: first, to point out that all leak
detection methods are not created
equal, and second, to provide a concrete example by discussing why it is
that line-leak detectors can find leaks
in satellite piping but inventory-control-based methods of leak detection,
whether traditional, SIR, or automated, cannot.2
The methods of leak detection
described in the federal UST rule are
tools we can use to find leaks. While
most people are familiar with visible
leak detection whereby you observe
drips from a faucet or a ceiling,
leak detection involving flammable
l iquids escaping from components
of a storage system buried beneath
the ground is a pretty esoteric topic
of discussion at most cocktail parties.
For this reason, I’ll start by discussing some tools that most people can
relate to: saws and hammers.
While saws and hammers can
both be used to build a wooden birdhouse, they have very different roles
to play in the construction process.
Likewise, automatic line-leak detectors and SIR can both be used to
detect leaks in pressurized piping,
but they have very different roles to
play because they operate on very
different principles.3 While it is obvious to most people why you can’t
drive a nail with a saw, it is perhaps
not so obvious why you can’t find
leaks in satellite piping with inventory control. Let’s start by looking at
the operating principles behind each
of these two methods of leak detection.
Operating Principles of LineLeak Detectors
Line-leak detectors operate on the
following general principles:
n Electronic line-leak detectors
(ELLDs) monitor pressure in
the piping between two defined
points. Usually these points
are the check valve in the submersible turbine pump (STP)
and the solenoid valve(s) in the
dispenser(s). Piping that is NOT
between these points in the piping system is not monitored.
n For the piping to be considered
tight, the ELLD needs to see
that the pressure in the piping
between the check valve and the
solenoid valve(s) remains reasonably constant during the test
period.
n Mechanical line-leak detectors (MLLDs) also use pressure
to find leaks in piping but the
operating principle is different. MLLDs want to see a rapid
rise in the pressure in the piping
when the submersible pump is
first turned on.
n MLLDs find leaks between the
point where the fuel leaves the
MLLD and the solenoid valve(s)
in the dispenser(s). Piping that is
7
■ Tank-nically
from page 7
Speaking
not between these two points is
not monitored.
n Both ELLDs and MLLDs work
by monitoring pressure in the
piping.
n ELLDs and MLLDs don’t give
a hoot how many gallons are
pumped through the piping each
hour or each day or each month.
To conduct a test, they must
monitor the pressure in the piping during a period when no fuel
is moving through the piping.4
Operating Principles of
Inventory Control
Inventory control operates on the following general principles:
➤Inventory is all about arithmetic.
Inventory is all about calculating how much fuel went into the
storage system, how much came
out, and how much is left. Inventory is an accounting procedure.
➤I nventory works by compar-
ing the volume of fuel delivered
(based on the bill of lading), the
volume of fuel dispensed (based
on the dispenser meter measurements), and how much is left in
the tank (based on ATG or gauge
stick measurements).
➤Measuring how much fuel goes
through the piping each day is a
key part of the inventory procedure.
➤Inventory finds leaks between
the fill pipe and the meter(s) in
the dispenser(s). If fuel leaves
the storage system for any reason between the fill pipe and
the meter(s) it will show up as
missing product in the inventory
records.
➤I nventory doesn’t give a hoot
about pressure; it works on both
suction and pressure piping systems.
➤Once the fuel has gone through
the dispenser meter and has been
accounted for, inventory has no
way of knowing what happens
to the fuel. If the dispensing hose
has a hole and one out of every
ten gallons that goes through the
8
TERMINOLOGY
Automated Inventory: A more recently developed method of leak detection where all of the inventory data are automatically gathered. Delivery
volumes, sales volumes, and volume in the tank are all simultaneously
recorded at frequent intervals throughout the day without any human intervention. Because no humans are involved in the data gathering, the accuracy of the data is greatly improved and the number of data points that can
be gathered is greatly increased. Proprietary statistical techniques are
applied to the data to determine if a leak may be present. As for SIR, automated inventory vendors must show that their software can detect leaks of
0.2 gallons per hour with a probability of detection of at least 95 percent
and a probability of false alarm of no more than 5 percent to be acceptable as a leak detection method. Because the data gathering techniques for
automated inventory are so different from the once-a-day data gathered for
SIR, automated inventory control must be evaluated using a different protocol. This protocol is commonly referred to as the Continuous In-Tank Leak
Detection (CITLD) protocol.
Check Valve: A valve in a piping system that only allows fluid to flow in one
direction. The flow of the fluid opens the valve and the valve closes automatically when fluid flow stops. In both pressurized and suction fuel piping systems, the check valve serves to keep the piping full of fuel when the pump is
turned off. In suction pumping systems the check valve is normally located
in the dispenser cabinet. In pressurized pumping systems the check valve is
located in the pump head at the top of the tank. The check valve in a pressurized pumping system is sometimes referred to as a “functional element”
because it serves as a pressure-relief device as well as a check valve.
Line-Leak Detector: In the federal regulations a line-leak detector is
defined as a device that will detect a leak in a pressurized piping system of
three gallons per hour within a time frame of one hour. The three-gallon per
hour leak rate is defined at a pressure of 10 pounds per square inch.
Master/Satellite Dispenser: Most long-distance trucks have two fuel
tanks, one on each side of the vehicle. To simplify and speed up the fueling
of these trucks, most truck stops provide fueling lanes where there are two
nozzles connected to a single meter so tanks on both sides of a truck can
be fueled at the same time in a single sales transaction. The dispenser that
contains the meter and the credit-card reader is called the master dispenser.
The dispenser on the other side of the vehicle has no meter or credit-card
reader (it’s basically just a stand to hold the nozzle) and is known as the
satellite dispenser.
Solenoid Valve: A solenoid valve controls the flow of a fluid using an electromagnet (solenoid) to open and close the valve mechanism. In a fuel
dispenser, the solenoid valve controls the flow of fuel to the nozzle. The
solenoid valve is normally closed and opens only after a method of paying
for the fuel has been established. Solenoid valves are in the closed position
when both mechanical and electronic line-leak detectors conduct a test.
Statistical Inventory Reconciliation (SIR): A method of leak detection first developed in the 1980s that takes traditional inventory data and
applies statistical techniques to these data to determine whether a leak may
be present. The statistical techniques used by each SIR vendor are usually proprietary. To be acceptable as a leak detection method, a SIR vendor
must show that their software can detect leaks of 0.2 gallons per hour with a
probability of detection of at least 95 percent and a probability of false alarm
of no more than 5 percent.
Traditional Inventory: Inventory control that uses simple arithmetic to
analyze the inventory data. The sum of the daily variances at the end of the
month is compared to the regulatory standard of 1 percent of sales plus 130
gallons to determine whether the inventory data may indicate a problem.
This standard will find leaks of about a gallon per hour with a probability of
detection of 95 percent and a probability of false alarm of 5 percent.
meter falls on the ground instead
of going into a vehicle, the inventory records will still come out
perfectly (assuming there are no
other holes in the system). Inventory has no way of knowing
where the fuel goes after it leaves
the meter.
➤Inventory is like a bank account.
You track how much is deposited, how much is withdrawn,
and how much is left. If you
withdraw $50 from an ATM (the
equivalent of a dispenser meter),
the bank subtracts $50 from
your account and the reconciliation at the end of the month will
accurately reflect the remaining
funds in your account. But there
is no way for the bank to know
whether you spent the $50 on
food, or movies, or clothes, or
whether the money fell out of
your pocket and was lost.
What Happens When These
Operating Principles Are
Applied to Satellite Piping?
➤With regard to the satellite pip-
ing that runs between a master dispenser and a satellite
dispenser, consider the following: In a master/satellite dispenser setup there is only one
meter. The whole purpose of the
master/satellite dispenser is so
that two nozzles can be used to
simultaneously fill the tanks on
both sides of a truck in a single
sales transaction. In today’s electronic world it would be possible to use two meters, one in
the master dispenser and one in
the satellite dispenser, and automatically add the volume measured by each meter to calculate
a total volume dispensed. But
satellite dispensers go back to a
time when all meter mechanisms
were mechanical, and adding the
sales volume from two meters
and calculating the cost would
have involved pencil and paper
and a mathematically competent
fueling attendant. While technology today is vastly different, the
tradition of a single meter in the
master dispenser persists.
➤In the early master/satellite dis-
Figure 1
Figure 1. In the earlier days of master/satellite dispensers, a single sole-
noid valve was installed upstream of the point where the satellite piping
branched off the master dispenser piping. The single solenoid valve controlled the flow of fuel to both the master and satellite nozzles. Line-leak
detectors conduct their tests when the solenoid valve is closed, so they
cannot “see” leaks beyond the solenoid valve. When the piping was set up
in this way the satellite piping was not in compliance with line-leak detection requirements. The satellite piping is also downstream of the master
dispenser meter, so inventory-based leak detection methods would not
find leaks in the satellite dispenser piping.
Figure 2
Figure 2. These days, two solenoid valves are installed in master/satellite
dispensers. Because there are no valves in the piping between the lineleak detector and the satellite piping, the leak detector can “see” leaks in
the satellite piping and the satellite piping is in compliance with line-leakdetection regulations. But the satellite piping is still downstream of the
master dispenser meter, so inventory-based leak detection methods still
cannot be used on satellite dispenser piping.
pensers, a single solenoid valve
9
from page 9
Speaking
was positioned in the piping
before the point where the piping to the satellite dispenser
branched off from the master
dispenser piping (see Figure 1).
Because both MLLDs and ELLDs
do their testing when the solenoid valve is closed, this meant
that the piping to the satellite dispenser was beyond the solenoid
valve and leaks in the satellite
piping would not be detected by
either a MLLD or ELLD. Fortunately, the technology to solve
this problem was quite simple:
just use two solenoid valves,
one in the master dispenser and
one in the satellite dispenser.
The solenoid valve in the master dispenser is positioned after
the point where the satellite piping branches off from the master
dispenser piping (see Figure 2).
Because there is no valve between
the line-leak detector and the satellite piping, leaks in the satellite
piping can be detected by both
MLLDs and ELLDs.
➤W hile there are two solenoid
valves in master/satellite dispensers sold today so that lineleak detection for satellite piping
is typically not a problem, master/satellite dispensing systems
still have only one meter in the
master dispenser. Inventory cannot know what happens to fuel
after it leaves the meter in the
master dispenser. If there is a
hole in the piping that leads to
the satellite dispenser, the inventory records will still come out
perfectly (assuming no other
holes in the system) because the
fuel has gone through the meter
and has been accounted for. This
is true for all inventory-based
leak detection systems, including
traditional inventory reconciliation, SIR, and automated inventory systems certified under the
continuous in-tank leak detection (CITLD) protocol.
SIR and automated inventory are
certified by the manufacturer to find
leaks in piping and these methods
are accepted by the National Work
10
Amen
So there you have it. Because of
their different principles of operation, MLLDs and ELLDs can find
leaks in satellite piping if the solenoid valves are set up correctly, but
inventory control, no matter where
the solenoid valves are located or
how automated or sophisticated the
inventory analysis, cannot find leaks
beyond the dispenser meter. This
could change someday if a second
meter were installed in the satellite
dispenser, but as far as I know, there
is no such satellite dispenser in existence today.
Any other leak detection questions? Send me a note at: marcel.
moreau@juno.com ■
Endnotes
1. Federal Register, Vol. 53, No. 185, September 23,
1988, p. 37142.
2. See terminologies that accompany this article for
the distinctions I make among these three methods of inventory control.
3. For purposes of this discussion, I’m going to set
aside the different sizes of leaks that line leak
detectors and SIR are able to detect. The point
I want to make is that SIR cannot find leaks in
satellite piping no matter how big the leak might
be.
4. For a more detailed discussion of the workings
of line leak detectors, see “Of Blabbermouths
and Tattletales: The Life and Times of Automatic
Line Leak Detectors,” LUSTLine Bulletin #29,
June 1998, available in the LUSTLine archives at
www.neiwpcc.org.
5. Federal Register, Vol. 53, No. 185, September 23,
1988, p. 37157.
NEW LUSTLINE T-shirts
Short-sleeve:
S – XXL: $10
Long-sleeve:
S-XXL: $15
To order:
Visit www.neiwpcc.org/portal or email
lustline@neiwpcc.orgg
S.T.LI
U.
NE
But Wait, You Protest…
Group on Leak Detection Evaluations (NWGLDE) as piping leak
detection methods! That is correct,
these methods can be used for leak
detection on pressure and suction
piping in general, they just can’t be
used for satellite piping. Although
the certification protocol is silent
on whether these methods apply to
satellite piping, I’m hoping that the
discussion above has made it clear
that these methods will not find
leaks in satellite piping.
Then how come the rules don’t
include traditional inventory control
as a piping leak detection method?
Good question. It is clear that traditional inventory will detect leaks in
piping (except satellite piping) if the
leak is big enough and the inventory
records are kept carefully enough.
I couldn’t find a direct statement
in the preamble of the 1988 federal
rule for why traditional inventory
is not an acceptable leak detection
method for piping. I think it can be
inferred from the discussion in the
preamble that USEPA did not believe
that traditional inventory, which the
agency determined could only reliably detect leaks of a gallon an hour,
was sufficiently protective of human
health and the environment in light
of the risk of large leaks posed by
pressurized piping.5
L.
■ Tank-nically
New England
Interstate
Water Pollu
tion Control
Commission
Three Insurance Agents Prosecuted in
Michigan UST Insurance Scam
by Ellen Frye
O
ver a two-year period the
USEPA and FBI uncovered and disrupted a fraud
scheme by insurance agents who
fabricated insurance certificates for
underground storage tanks (USTs) in
Michigan. Once the scheme came to
light, on a tip, USEPA and FBI agents
initiated an undercover operation
in the Lansing, Michigan area. The
undercover operation documented
that the participants were selling
fake insurance certificates for cash to
gas station owners who were unwilling to pay the substantial cost for
genuine UST insurance.
The investigation determined
that, between 2011 and 2013, insurance agents Dean Tucker and Allen
Chadderdon sold approximately
175 fake certificates to gas station
owners in more than 30 different cities, including Battle Creek, Lansing,
Manistique, Ann Arbor, and Detroit,
earning them over $80,000.
C h a d d e r d o n a n d Tu c k e r
obtained hundreds of dollars (and
sometimes substantially more) in
cash payments for each fake document sold. That money was pure
profit to them—there was no actual
policy behind the certificate. A third
insurance agent, Jeff Ashton, bought
certificates from Tucker and Chadderdon and resold them to his clients. Criminal search warrants were
served at the insurance agents’ business offices on October 8, 2013.
Federal and state regulations
require owners and operators of
certain USTs to provide assurance
that they can finance a cleanup in
the case of a spill or leak. In states
without state assurance funds, most
owners and operators comply with
this requirement by obtaining liability insurance. However, gas station
owners with tanks more than 30
years old, or with an “open release
status” or an “existing pollution condition” due to a previous or ongoing
leak, are typically charged far more
for their UST insurance. Insurance
companies can also require costly
and time-consuming environmental
studies prior to issuing a policy.
Tucker and Chadderdon took advantage of this
situation by offering clients
a fake certificate of insurance to show to regulators.
The fake certificates concocted by Chadderdon and
Tucker looked identical to
genuine insurance certificates and could easily trick
an UST inspector to believe
that the owner had the necessary insurance in place.
Immediately following the disruption of the
criminal scheme, USEPA
and Michigan Department
of Licensing and Regulatory Affairs
(MDLARA) regulators swung into
action, inspecting the gas stations
that had received the fake certificates. News of the criminal investigation had become known to many
of the gas station owners, and some
of them quickly obtained valid insurance. Gas stations that were unable
to come up with proof of valid insurance were “red-tagged” (i.e., shut
down until insurance was obtained).
Financial Coverage Is a Must
The potential for harm to the communities in which these stations
operated without valid insurance
is obvious. A leaking underground
storage tank impacts not only the
land immediately surrounding the
tank, but can also endanger a community’s water supply and contaminate waterways as it travels
underground or through storm
drains. 1 This is why both federal
and state regulations require owners
and operators of USTs to prove that
they have the financial wherewithal
to remediate any pollution and compensate those injured by a release
from an UST.
The insurance policies available
in the market ensure that owners and
operators of USTs have $1 million in
available coverage to respond to a
leak. According to state cleanup programs, the average cost to clean up
a site is $125,000. Also important, if
an UST is uninsurable in the market,
the owner must update the aging
tanks or otherwise bring the facility into compliance. Since the inception of the federal UST regulations,
more than 1.8 million USTs have
been closed; there were fewer than
7,000 confirmed releases in FY14;
and 447,000 cleanups had been completed by the end of FY14.
The Penalties
Tucker and Chadderdon pled guilty
to fabricating the insurance certificates in federal court in Grand
Rapids, MI. On December 3, 2014,
Chadderdon was fined $20,000 and
imprisoned for one day and required
to perform 200 hours of community service. On March 5, 2015,
Tucker received the same sentence.
On February 6, 2015, Jeff A shton
was charged in relation to the fraud
scheme. On June 08, 2015, he was
sentenced to: 30 days of home confinement included in 24 months
of probation. The sentence also
included a $5,000 fine; 200 hours of
community service; attending a substance abuse treatment program;
surrender of his insurance license;
and a $100 special assessment. In a
separate action, in March 2015 the
Michigan Department of Insurance
and Financial Services revoked both
Tucker ’s and Chadderdon’s insurance licenses.
“About half of the nation’s
population gets its drinking water
11
Unlocking the Mystery of FR
A straight-talking column by Jill Williams Hall, Senior Planner with the
Delaware Department of Natural Resources and Environmental Control
(DNREC). She can be reached at jill.hall@state.de.us.
How Do You Know That an
FR Document Is for Real?
T
he recent insurance scam
uncovered in Michigan has
caused state inspectors to ask
some important questions, such as:
How do I know whether the same
type of scam is happening in my
state? Should I be doing something
differently? Unfortunately in today’s
era of technology there are no easy
answers to the dilemma of verification of paper documentation. With a
computer and a little ingenuity you
can produce virtually anything on
paper—diplomas, money, fake insurance certificates. So what can one
expect of state UST inspectors when
they review financial responsibility
documents? Call the insurance company to verify? Can we reasonably
expect that states have the staffing
levels to call the insurance company
on every insurance certificate for
every UST site? The simple answer is
”no.” So what can we do?
• First and foremost, the state
must require some reasonable
form of documentation—either
a copy of the insurance policy
or alternately a certificate of
insurance—this is not simply
an Acord form, the insurance
industry standardized form. An
Acord form does not supply the
minimum information required
to ensure that appropriate insurance is in place. Minimally the
documentation must be at least a
certificate of insurance that mirrors the one found in the federal
UST regulations. In addition, it is
not a bad idea to request a copy
of the “Declarations” page of
the insurance policy. While both
the certificate and the Declarations page can be falsified, the
information provided on those
documents can then be verified. Requiring the Declarations
page in addition to the certificate
would require that a nefarious
individual would have to put in
some extra effort to create both
12
a certificate and Declarations
page. Might this act as a deterrent due to the extra effort and
knowledge required on the part
of the individual doing the falsification? Perhaps.
• Once you have in hand a policy
or certificate of insurance, ensure
that your inspectors know what
they are reviewing. The USEPA
document Financial Responsibility for Underground Storage Tanks:
A Reference Manual (www.epa.gov/
oust/pubs/frustman.htm) and the
Association of State and Territorial Solid Waste Management
Officials guidance document
Guide to Tank Insurance (www.astswmo.org/Pages/Policies_and_Publications/Tanks.htm) are excellent
resources. Make sure inspectors
do a comparison of the language
in the submitted certificate of
insurance with the required
language in your state regulations. If the certificate of insurance deviates from the required
language do not accept it as
documentation. Require a resubmittal of the certificate that has
the exact language required by
regulation.
• Do a certain percentage of spot
checks every year. Pick a reasonable number that you know your
staff can support and have them
call the insurance company on
the policy or certificate to verify
that 1) the insurance company
exists, 2) all the information
submitted agrees with what the
insurance company has on file,
and 3) the signature is that of a
valid representative of the company. As your inspectors become
more seasoned and familiar with
correct documentation they’ll
learn to spot discrepancies.
Empower and encourage them
to verify any information that
doesn’t seem ”quite right.” This
becomes a bit of an art, rather
than a science, where you learn
to rely on your intuition. Follow
those instincts—it won’t hurt
to verify information but it may
hurt not to.
• Create a list of insurance companies that you have verified are
legitimate companies licensed to
sell tank insurance in your state.
Currently the number of insurance companies offering tank pollution liability insurance is fairly
limited. New companies do come
along, so if you spot a name that
is not on the list, do the required
research and see if you need to
add it or if you have uncovered a
false company. Partner with your
state insurance commissioner’s
office—they have the insurance
expertise you need.
• For the more sophisticated forms
of financial responsibility such
as bonds, letters of credit, and
guarantees you may want to
partner with a sister state agency
with financial expertise, if such
expertise does not exist in your
agency. UST staff typically have
technical scientific backgrounds,
not financial. If something is
out of your league be willing to
admit it, not ignore it, and reach
out to find assistance. Create a
partnership with a sister financial agency and ask if they can
review financial documents.
Remember the only stupid question is the unasked one.
• And always keep in mind that
educating our tank owners and
operators is the best defense.
In the end, if a release occurs
and they have no valid financial
responsibility mechanism, they
are the ones who stand to lose
their livelihood. ■
Getting to That High-Hanging Fruit
Building Consensus Through Corrective Action Conferences
by Jeff White
T
his is the tale of how the
Iowa Department of Natural
Resources (DNR) developed its
system for making difficult decisions
for leaking underground storage tank
(LUST) sites. I’ll discuss how the corrective action (CA) conference process
fits in the Iowa Risk-Based Corrective
Action (RBCA) program; why the
conferences were implemented; how
we quantify CA outcomes; how the
conferences are managed to facilitate
consensus; and finally, I’ll provide
an assessment of successes and challenges of the CA process.
First, let’s go back to 1995 when
the Iowa Legislature enacted the
initial legislation for UST regulation in the state. The UST Section of
the Iowa DNR was established to
regulate fuel systems and address
releases from those systems. The
regulations required that contaminated sites—those that “failed” site
checks—undergo assessment and be
classified as high risk, low risk, or no
action required (NAR).
In 1989, the Iowa Legislature created the Comprehensive Petroleum
Underground Storage Tank Fund
(the Fund), an independent organ
ization designed to provide reimbursement for the assessment and
cleanup of LUST sites. To qualify for
the funding program, all UST sites
had to undergo site checks (i.e., soil
and groundwater sampling) to determine whether the fuel systems had
leaked. Those site checks had to be
completed by October 26, 1990.
By the 1990s and early 2000s,
high-risk LUST sites with singlecontaminant plumes, nearby drinking water wells, or vulnerable water
lines—the low-hanging fruit—were
successfully addressed using tried
and true CA approaches (e.g., overexcavation, plugging water wells and
providing an alternative water source,
or replacing vulnerable water lines).
In 1997, a relatively complex
RBCA system was initiated to evaluate risk to human health and the
environment from UST releases. The
system, still in use today, consists of
a three-tiered approach for evaluating risk. Tier 1 is a simple assessment
that includes collecting a limited
number of samples and comparing contaminant concentrations to a
lookup table of standards. The Tier
2 assessment involves defining the
extent of contamination and using
predictive contaminant transport
models to determine risk. The Tier 3
assessment allows a less structured
and more creative approach that
can be used instead of or after Tier
2 to evaluate or reevaluate risk. For
example, a high-risk drinking water
well might be cleared in Tier 3 by
demonstrating that the water well
pumps from a “clean” aquifer that
is geologically isolated from the contaminated aquifer.
Our Quagmire
By 2004, CA efforts for nearly 1,200
high-risk sites had bogged down
because of difficulties reaching consensus about methods for addressing these more complex challenges.
Many high-risk sites stalled at the
post Tier 2 stage due to a CA process
that was complex, cumbersome, and
simply not working well.
Between 1987 and 2004, the process for determining CA technology
went like this: The DNR accepted
the Tier 2 Report as high-risk and
required the responsible party (RP)
to hire an environmental consultant
to develop a CA plan. The consultant (Iowa Certified Groundwater
Professional or CGP) submitted a CA
proposal with estimated costs to the
RP (usually the property owner) and
the Fund. The Fund would accept
or reject the proposal; if the Fund
accepted it, the CGP prepared and
submitted a corrective action design
report (CADR) to the DNR and the
Fund. If the Fund rejected the proposal, the CGP submitted a new proposal or the Fund put the CADR out
to bid. Eventually a CGP completed
a CADR, the DNR reviewed the
CADR and if DNR accepted it, the
CGP was directed to implement the
CADR and provide reports to all.
The hitch was that the remediation or CA approach that was
acceptable to the Fund might not
be acceptable to DNR or vice versa.
Thus, the inefficiencies built into the
process had the potential for multiple resubmittals of plans and budgets attempting to satisfy the various
approval authorities. Further, if a
large, complex site needed multiple
CA events, the proposal process
could take years. And no one person
knows all about remediation technologies, success rates, costs, and site
conditions. We were deep into backlog country.
Finding a Solution
As a result of the backlog, in July
2004 the DNR sponsored an intensive, week-long business process
improvement event to explore
options to develop efficiencies in
managing a LUST site from start
to finish. Representatives from the
DNR, CGPs, the Fund, Petroleum
Marketers Mutual Insurance Company, and RPs participated in this
event. During that event it became
apparent that the quagmire in the
RBCA process was moving a highrisk site from monitoring into corrective action. The focal point then
became how to better support consensus and achieve more corrective
action. 1 The group examined the
existing system and identified causes
for delays.
The general outcome of this complex and somewhat tedious process
was a system of structured corrective
action conferences and designation
of a CA specialist whose main function is to facilitate the conferences
(facilitator).
Corrective Action
Conferences
At these conferences, the DNR facilitator, the DNR project manager, the
RP, the CGP, and representatives
of the funding agency (the Fund or
other insurance company) meet in
person or by conference call to pose
13
■ Corrective
from page 13
Action Conferences
questions and discuss the site. At
times, other interested parties (e.g.,
city personnel, adjacent property
owners, DNR staff from other sections) also participate. They discuss,
for example, current tanks status,
findings of prior investigations, or
challenging geological and physical
site characteristics; explore funding
options; and consider possible corrective action approaches or technologies. The initial plan was for
each site to have one or two conferences. Half the sites needed only one
conference. However, in the past 10
years, 1 percent have involved four
or more conferences, and two sites
needed nine meetings.
The goal of each conference is
to remove barriers to CA and reach
consensus on a plan and schedule
in order to move the site to closure.
Once the details of the plan have
been hammered out, all parties
sign a memorandum of agreement
(MOA). Initially the MOA was a
“handshake” agreement, but in 2008
the Iowa Administrative Code was
amended so that an MOA becomes
a legally binding document between
the DNR and the RP. Although CA
conferences began in 2004, the fulltime facilitator was added to the UST
staff in 2005 after the DNR obtained
additional funding from the USEPA.
The Facilitator
For the facilitator, preparation and
structure are the keys to conference
success. Preparation ensures that all
participants come to the conference
knowing as much as possible about
the history, geology, and other factors unique to the site. The facilitator must work closely with the DNR
project manager to schedule the conference; require the CGP to provide a
detailed worksheet (with recommendations) at least 10 days before the
first conference; send out reminders of the upcoming conference; and
understand the history and conceptual site model.
Structure ensures that participants feel comfortable participating
and know how to contribute to the
discussion. The facilitator provides
a consistent agenda; promotes inclusiveness and respect from all participants; steers the discussion toward
14
consensus; takes careful notes of
the conversation and decisions; and
provides detailed notes to the DNR
project manager for review and dissemination.
Besides scheduling, facilitating,
and providing detailed notes on the
conferences, the facilitator serves
as a resource for technical review
of CADRs, remediation proposals,
remediation monitoring reports, and
Tier 3 reports. The facilitator also
maintains a database to track report
submittals, remediation startups and
shutdowns, and other significant
events.
Track Record
The UST Section conducted its first
CA conferences in July 2004, and
generally held six to eight meetings
a week. In 2004 and 2005, staff held
471 conferences. However, starting in 2006 the number of corrective
actions—remediation or Tier 3—
undertaken for the higher-hanging
fruit increased significantly while
the number of conferences gradually
decreased to an average of about 60
conferences per year. From inception
through the end of 2014, just over
1,200 conferences have been held to
discuss CA plans for more than 630
LUST sites.
Why has this approach worked?
Communication leads to consensus.
We meet, talk, and work together,
With a Little Help from
Forensics
One success story involves a LUST site
in eastern Iowa that has free product,
increasing groundwater BTEX concentrations, and a nearby drinking water well.
In a series of four conferences in 2011
to 2012, the conference participants
commissioned additional investigation,
including product forensics, and determined that the product and contamination
were not from a new release. A subsurface, laser-induced fluorescence survey
suggested that the LNAPL is primarily
held in fractures within the unsaturated
clay matrix. Participants agreed to conduct a pilot test and install a soil vapor
extraction system, if appropriate. The
pilot test showed potential; the system
was installed in 2013; and reports indicate the system is working well.
and get to know and trust each other.
Conferences generally are the only
occasions for CGPs to meet and get
feedback from the Fund, the facilitator, and their DNR project managers. RPs get their concerns addressed
and questions answered, receive
regulatory and scientific viewpoints,
and have a platform to provide their
viewpoints and tell their stories. For
example, one station owner’s business was located in a community near
a major recreational lake in Iowa. He
expressed concerns that his site not
be shut down to conduct an excavation during the summer, the height
of his busiest season. We were able to
schedule work around his concerns.
Successes
Over time, the CA conference
approach has demonstrated several key strengths. First, the framework has been structured in a way
that promotes input from all parties
but is flexible enough to support
the negotiations and steps toward
consensus on CA plans for difficult
sites (e.g., highly contaminated sites,
commingled plumes, recent releases,
complex stratigraphy, or combinations of these factors). The process
has allowed us to adapt to changes
in regulations, funding constraints,
fluctuations in the industry, and
developments in technology. Conferences have improved communication and transfers of knowledge and
increased trust. But the most crucial
outcome is that corrective actions are
being implemented, and LUST sites
are being closed.
In over ten years, 97 percent of
the conferences have been successful.
The conferences concluded with a
plan that outlined practical, innovative, cost-effective technologies and/
or established approaches for alternative assessments under Tier 3; set
schedules for work and reporting;
specified funding; and guided CA at
LUST sites across the state. A review
of the site records reveals that conference participants selected the following :
• Tier 3 alternative evaluations
such as demonstrating plume
stability (40% of the sites)
• Excavating contaminated soil
and treating at a soil landfarm/
landfill (25%)
.
ander L U
W
..
...
aw
ab
alk
ST
o u t w i t h Jeff
Kuh
.
n.....
........................
Jeff Kuhn is with the Montana Department of Environmental Quality (MDEQ) and a venerable veteran of petroleum
remediation at the state and national levels. Through this
column he takes us on “walkabouts” across the fascinating world of underground storage tanks. Jeff welcomes
your comments and suggestions and can be reached at
jkuhn@mt.gov.
Nuggets of Time
M
ost towns in Montana
come alive in June as winter snow recedes and the
weather warms. Suddenly everyone
tries to get it all in before the snow
flies again in the fall—which can be
any time after Labor Day, or for that
matter, tomorrow. Folks who live in
northern climates are especially sensitive to the passage of the seasons,
and of time itself. My friends in New
England really felt it this year.
Recently I was reminded of the
passage of time when our office
moved to a new location, necessitating some high-level sorting of
stratigraphic layers of dusty, faded
publications, notes, and files. Housecleaning is a good exercise and generally cathartic in nature. But I was
immediately struck by the immensity
of work associated with so many projects undertaken over the years—work
representing the collective efforts of
many, many people. Some of these
projects had profound implications
for the development of the program.
Others were well intended, but in
retrospect had limited scope or were
quickly superseded by more important, rapidly evolving issues.
I’m not suggesting that anyone
could have had the foresight to save
the time and effort expended on any
of these projects. Each was significant and fulfilled a specific purpose.
State program needs can change very
quickly. When the UST Program was
created, the first USEPA Office of
Underground Storage Tanks (OUST)
Director, Ron Brand, and USEPA coworkers insisted on developing a new
state program franchise approach that
encouraged partnership, innovation,
and creativity to address unique state
program needs.
In his 2013 book, True Green,
Brand provides some insight into the
origin of this new program: 1 “In a
publication we issued, we said: ‘Perhaps the best way to begin defining
EPA’s responsibilities is to say what
the Regional Offices will not be doing:
• They won’t run the UST program for the state
• They won’t dictate behavior at
the state level
• They won’t second-guess individual state decisions’.”2
What Ron Brand started has continued with a great deal of momentum behind it. The National Tanks
Program has learned a lot in its 30
years. It has been an exceptional
model for state-federal partnership,
and is distinctly different from other
federal grant programs.
This partnership has created an
open line of communication that gives
OUST the distinct advantage of being
able to “think on its feet” and better
respond to state needs. On a federal
level, OUST has been incredibly open
to the input of states. When disagreements occur they are typically quickly
resolved through the leadership of
state and federal program contacts
involved in forums such as the Association of State and Territorial Solid
Waste Management Officials’ (ASTSWMO) Tanks Subcommittee. State
UST/LUST programs have reaped
the benefits of that collaboration and
the open dialogue created by partnership. We should all applaud OUST
for that effort—states really want to
see that open dialogue continue.
And Then Came Email…
Email…Email
As I sorted through paperwork from
years of program management I was
more and more amazed at the level
of human effort that went into each
memo and letter written before the
use of internet email. How did we do
anything before email? The changes
wrought by this simple tool are staggering. Although email creates its
own nightmares, I can think of no
other tool that has so revolutionized
the way our programs interact with
partner agencies and all of our stakeholders. We now have the ability to
quickly share ideas and gain consensus on issues. In fact, most days it is
difficult to keep up with the constant
15
■ Nuggets
of Time from page 15
stream of information as online
discussions evolve (or devolve).
Entropy, the “lack of order or
predictability; gradual decline into
disorder”seems to parallel the principle that even the most well-intended
email discussions can quickly unravel
and go the wrong direction.3 Those
who depend heavily on email usually hit critical mass at some point
and resort to a time-proven method of
communication—the phone—crude
technology, but very effective.
After separating out project-specific, legally sensitive, and milestone
documents, I was left with a slowly
advancing glacial mass of paper representing years of hard work, staff
discussions, countless meetings,
workgroup notes, and phone calls.
I even found a pile of the small telephone message notes we speared on
metal prongs on top of our desks—
now gone like my rolodex.
The Nuggets
As I continued to sort and pile paper
for recycling I thought about time
on a human scale versus the concept
of time, which provides a different
frame of reference for geologists.
After all, I tell my wife, “it took a
million years for soil to form in the
yard. Can’t the bathroom remodeling
project wait just a little longer?” But
she is a professional musician, and
all great symphonic works have a
definite beginning and ending. They
don’t just fade away in geologic time.
With that thought I returned
to my office purging of old paper
files, thanking Ron Brand for setting
in motion an UST/LUST program
paradigm that gave birth to each
of the nuggets—publications, concepts, enhanced understandings and
approaches, new tools and technologies—the prizes of hard-earned work
right up to the present that I rediscovered. For example:
• MUSTs for USTs • Total
Quality Management—
TQM • Revelation
Database • LUSTLine articles
tracking timely topics • Lab
in A Bag • Program
Streamlining • Straight Talk
on Tanks, Don’t Wait Until
16
’98 • ’98 Report Card of
the UST Program • State
Trust Funds • RiskBased Corrective Action
(RBCA) • USTfields • Ready
for Reuse • Green Gas
Stations • the Petroleum
Equipment Institute’s (PEI’s)
development of numerous
UST-related Recommended
Practices • OUST memo
(Sammy Ng) allowing
tank removal as part of an
investigation at LUST Trust
sites • ASTSWMO’s MtBE
Workgroup • OUST Backlog
Report • and from more
recent time, my notes from
many ASTSWMO Core Report
meetings…and the list goes on.
Each of these program initiatives
bear testimony to a tremendous partnership involving federal, state, tribal,
local, industry, and environmental
consulting representatives, all collaborating in a way that has shaped the
UST Program as we know it today.
How can we know where we’re going
if we don’t value where we’ve been
in the past? It’s important for those
who come after us to value both our
successes and our failures if they are
to value the evolution of the program
and the close working partnerships
we’ve fostered.
How can we know where we’re
going if we don’t value where
we’ve been in the past? It’s
important for those who come
after us to value both our
successes and our failures if they
are to value the evolution of the
program and the close working
partnerships we’ve fostered.
web of connections and the collective
efforts of so many good people I’ve
worked with—so many nuggets of
time.
Back to the Future
It’s the weekend now and the June
sun has risen to the point of obliterating the screen on my laptop. The
magpies are crowing incessantly, and
my coffee is cold—time to get started
on Saturday morning chores. My son
has no concept of spearing phone
messages on a metal prong, of hand
typing memos on a typewriter, or of
walking from cubicle to cubicle to
poll staff members about a suitable
meeting time. He lives and breathes
in cyberspace—the electronic world
where ideas are communicated in
milliseconds.
But hey, my son now has a phonograph; listening to scratchy old
vinyl LPs is apparently very much
in these days. It’s great when the
next generation rediscovers what we
already knew worked well and was,
well, cool. And despite federal budget cuts I’m hopeful for the future of
the tanks program. I don’t see environmental cleanup easing up anytime
soon. The state-federal partnership
that undergirds the UST program is
healthy and fully engaged, demonstrating that some ideas are just plain
good ideas that stand the test of time.
Bill Torrey, a well-known USEPA
Region 1 program manager, captured
the sentiment this way:
“The theme of the office was to make
states successful. We appreciated how
OUST empowered states and offered tools
and flexibility so that states could find
creative solutions to UST challenges.”
Thanks Bill, I couldn’t agree
more. It’s a great feeling to be part of
such a partnership and understand
the model it represents for other federal programs. Time to look toward
the future as the program rolls on! ■
Endnotes
1. Ron Brand, in “True Green: Executive Effectiveness in the U.S. Environmental Protection
Agency,” Dec. 6, 2013.
2. U.S. EPA. 1989. Commitment to Cooperation:
Franchising the UST Program. EPA/530/UST89/011.
3. Definition of entropy: http://www.oxforddictionaries.com/us/definition/american_english/entropy.
As I did my sorting, I suddenly
sensed with satisfaction the weight of
things gone right—cleaning out the
cobwebs yet keeping the tremendous
4. Bill Torrey quote in “Underground Storage Tanks: Building on the Past to Protect the
Future,” EPA 510-R-04-001, USEPA Office of
Underground Storage Tanks, March 2004.
■ Corrective
from page 14
Action Conferences
• Installing or modifying a remediation systems, such as air
sparging (25%)
• Modifying or eliminating a
receptor, such as plugging a
drinking water well (7%)
• Other options (3%)
By the end of 2014, the highrisk backlog had been reduced to
fewer than 480 sites. Approximately
4 percent of the conference sites
have reached NAR classification,
and NAR classifications generally
increase each year.
Opportunities
The conferences have become a vehicle for discussion and experimentation with changes in rules, guidance,
and procedures. For example, vapor
intrusion risk in Tier 2 has been
based upon 1995 ideas and sampling procedures. However, during
some CA conferences DNR staff, the
facilitator, and CGPs have discussed
procedures to re-evaluate risk for
Tier 2 high-risk receptors in Tier 3
using ITRC/USEPA-recommended
vapor intrusion guidelines. Also,
new techniques for investigation and
remediation of soil and groundwater
contamination have been proposed,
explained, discussed, and evaluated
inside and outside of conferences.
Some challenges remain. For
example, how do we get unfunded
sites to implement CA? How should
we address sites with persistent free
product/LNAPL and determine
when free product has been removed
to the extent practicable? How can
we reclassify the hundreds of lowrisk (monitor only) sites? Which
injection technologies work in which
subsurface materials under what
conditions?
Despite these challenges, the
CA conference process has proven
its worth as an effective means of
obtaining consensus and remediating LUST sites. ■
■ Insurance
from page 11
Agents Prosecuted
from groundwater supplies,” said
Randall K. Ashe, Special Agent in
Charge of USEPA’s criminal enforcement program in Michigan. “Leaking underground storage tanks pose
a significant threat to the quality
and safety of that groundwater. To
protect human health and the environment, EPA must receive accurate and honest documents. These
recent pleas demonstrate that insurance agents who callously place the
American people at risk by falsifying official certificates will be held
accountable for their actions.”
The case was investigated by a
law enforcement task force consisting
of the United States Postal Inspection
Service, the Michigan Department
of Natural Resources Environmental
Investigations Section, and the Lansing Police Department in addition
to USEPA’s Criminal Investigation
Division and the Federal Bureau of
Investigation. ■
Endnote
1.Iowa DNR. 2009. Kaizen Corrective Action Process.
http://www.iowadnr.gov/InsideDNR/RegulatoryLand/
UndergroundStorageTanks/LeakingUndergroundTanks/
LUSTCorrectiveAction.aspx.
Jeff White is with the UST Section
of the Iowa Department of Natural
Resources. He is a certified groundwater professional and well contractor
in Iowa and a professional geologist in
Kansas and Nebraska. He is transitioning from being the CA Facilitator to
becoming the Enforcement Coordinator
for the UST Section. He can be reached
at jeff.white@dnr.iowa.gov.
Ellen Frye is the editor of LUSTLine.
For more information on this case, contact Richard Porter, USEPA, Criminal
Investigation Division Special Agent
(734) 692-7659, porter.rich@epa.gov,
or Erick Thorson, Michigan Department of Natural Resources, Environmental Investigation Section Detective
(586) 753-3720,
thorsone@michigan.gov.
SNAPSHOTS FROM THE FIELD
Endnote
1. One example is the release of diesel fuel from a
gas station UST in November, 2006 in Luna Pier,
Michigan, which resulted in more than $1 million
in cleanup costs. The subsequent investigation
determined that the station owner had failed to
maintain insurance coverage for the UST.
Here’s what can happen when you improperly anchor ballast to a new tank in high
groundwater.
Photo by Ryan Harrigan, CT@T
L .U.S .T.Li
ne
Index
August 1
9
85/Bulle
tin #1 –
Decemb
er 2014/B
ulletin #
76
Downloa
d
the In
www.ne
iwpcc.or dex at
then clic g/lustline/
LUSTLin k on
e Index.
17
FAQs from the NWGLDE
…All you ever wanted to know about leak detection, but were afraid to ask.
How to Get a New Leak Detection Device Listed on
the NWGLDE Website
In this issue’s FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE) we discuss the procedure that must be
followed before a leak detection device may be listed by the NWGLDE. Please note: the views expressed in this column represent those
of the work group and not necessarily those of any implementing agency.
Q.I have a new leak detection device, and I want to
reviewed and approved by the NWGLDE before a
review of the equipment evaluation could be undertaken.
get it listed on the NWGLDE website. How do I
do that?
A.This is a very basic question, but a detailed answer
could take several pages, so we will provide the following Reader’s Digest version. The NWGLDE website contains more details in Listing Procedures
and Requirements at www.nwglde.org/downloads/
listing_requirements_pdf.pdf and in the NWGLDE
Policy Memo #3 at www.nwglde.org/Policy3_PDF.pdf.
• Contact an independent, or “third-party,” evaluator to discuss having an evaluation of your
leak detection method.
”Third-party evaluators” include consulting firms,
test laboratories, not-for-profit research organizations, and educational institutions that have
no conflict of interest with you or your company.
The evaluator can tell you about specific evaluation requirements for your method, whether special testing equipment or facilities will be needed,
how long the evaluation process may take, and of
course, how they price their services. Evaluators
that have performed UST leak detection evaluations can be found in the lower right corner of all
NWGLDE leak detection equipment listings at
www.nwglde.org. After you have engaged an evaluator, you will receive a report summarizing results
of the testing process according to specific report
guidelines. Additional supporting documentation
may be submitted with the evaluation.
• Once the evaluation is completed, submit it to
the NWGLDE for review.
Submittal of a final evaluation is the last step in the
NWGLDE listing process and it can be complicated.
It is very important for vendors to understand that
serving on the NWGLDE is not a full-time job for
any member. Members work for individual states,
counties, or USEPA, and their first work obligation
is to their employer. Their NWGLDE responsibilities
normally take a back seat to the demands of their
employer. All members have agreed to make time
available to accomplish NWGLDE activities, but
there are times when member work demands may
cause a review to take longer than usual.
Work Group Policy Memo #3, which is referenced
above, states: For planning purposes, anticipate at least a
six-month review process for a complete evaluation package. If the evaluation submittal package is complete,
it would rarely require six months for a review.
However, if there are unanswered questions, additional documentation to be provided, or additional
testing needed, the review process could take six
months or longer. In order to ensure that the process
will be able to move forward, it is very important
to communicate with the NWGLDE throughout the
review process.
That being said, the review process itself is as
follows:
• Perfor m the evaluation according to an
approved protocol.
18
The NWGLDE has reviewed and approved numerous protocols for testing various leak detection
methods and equipment. NWGLDE-approved protocols are located at www.nwglde.org/protocols.html
on our website. One of them should be applicable
to your method; however, in years past it was not
uncommon for a new technology to appear before
there was an approved protocol for evaluating
it. This produced a “cart before the horse” situation for the NWGLDE whose mission is to review
third-party evaluations according to an approved
protocol. In those cases, the evaluator would need
to draft an applicable evaluation protocol that was
For some equipment, it might be necessary to modify or amend an existing protocol to make it applicable to the method or equipment being tested. If that
is the case, then the evaluator must make sure the
NWGLDE is aware of those protocol modifications
and in agreement with them before the evaluation
is done. It would be counterproductive to have to
redo an evaluation simply because protocol amendments were not acceptable to the NWGLDE, or never
shared with us in advance of the evaluation.
1. The evaluation package is distributed to members
of a specific review team according to leak detection technology. The teams typically consist of
two to four persons and are subcommittees of the
FAQs… continued from page 18
entire group. A list of teams and team members
is posted on the NWGLDE website.
period to concur or express any concerns with the
draft.
2. Although all team members receive the package,
a lead reviewer often does the initial review.
10.After the members are satisfied with the draft listing, the chair sends it to the NWGLDE webmaster
who updates the website listing.
3. Any concerns or problems identified are discussed with the rest of the team and then with
the vendor.
4. If the vendor resolves the concerns, then the
review proceeds.
5. If the vendor is nonresponsive, the team may
suspend the review process.
More specific details of the review procedure can be
found in Work Group Policy Memo #3, available on the
NWGLDE website. ■
About the NWGLDE
The NWGLDE is an independent work group comprising eleven
members, including ten state and one USEPA member. This
column provides answers to frequently asked questions (FAQs)
the NWGLDE receives from regulators and people in the industry
on leak detection. If you have questions for the group, contact
them at questions@nwglde.org.
6. If the vendor disputes any concern(s) of the team,
there is an opportunity to bring the concern(s)
before the entire NWGLDE for further discussion
and resolution.
7. Once the team has finished its review and all
concerns are satisfied, a draft leak detection
method listing is developed. The team then
sends the vendor a proposal of how the listing
will appear on the NWGLDE List.
8. If the vendor has concerns, the team will work
with the vendor to resolve them.
9. If the vendor is satisfied with the listing, the
team leader sends it to the NWGLDE chair, who
circulates it to the entire NWGLDE with a set
New from ASTSWMO
Compilation of State UST Fund
Fraud & Abuse Cases
T
he Association of State and Territorial Solid Waste
Management Officials’ ASTSWMO Tanks Subcommittee’s State Fund–Financial Responsibility Task Force
has developed a new Compilation of State UST Fund Fraud
& Abuse Cases. The document chronicles instances of state
underground storage tank (UST) fund fraud and abuse
nationwide. The Task Force, through its regional members,
contacted every state to solicit entries for the document
spreadsheet. States were asked to be as specific as possible,
but were cautioned not to divulge anything that was confidential or they did not want to be made public.
The spreadsheet provides summaries of cases that
have been submitted to ASTSWMO by state UST managers,
including a description of the fraud cases, how they were
detected, and case outcomes. The intent of the spreadsheet
is to assist states in detecting any similar cases in their
own state. The Task Force will update the spreadsheet on a
regular basis. If you have examples you would like to add
to the next version you may send them to Charles Reyes at
charlesr@astswmo.org. The document is available on the
ASTSWMO website: www.astswmo.org. ■
NWGLDE’s Mission
•Review leak detection system evaluations to determine if each
evaluation was performed in accordance with an acceptable
leak detection test method protocol and ensure that the
leak detection system meets EPA and/or other applicable
regulatory performance standards.
•Review only draft and final leak detection test method
protocols submitted to the work group by a peer review
committee to ensure they meet equivalency standards stated
in the U.S. EPA standard test procedures.
•Make the results of such reviews available to interested
parties.
L.U.S.T.LINE
Subscription Form
Name_____________________________________
Company/Agency_________________________
Mailing Address _ _________________________
E-mail Address____________________________
❏
One-year subscription: $18.00
❏
Federal, state, or local government:
Exempt from fee. (For home delivery, include
request on agency letterhead.)
Please enclose a check or money order (drawn on a
U.S. bank) made payable to NEIWPCC.
Send to: New England Interstate Water
Pollution Control Commission, Wannalancit
Mills, 650 Suffolk Street, Suite 410, Lowell, MA
01854
Phone: (978) 323-7929 ■ Fax: (978) 323-7919 ■
lustline@neiwpcc.org ■ www.neiwpcc.org
19
L.U.S.T.LINE
New England Interstate Water
Pollution Control Commission
Wannalancit Mills
Lowell, MA 01854
Non-Profit Org.
U.S. Postage
PAID
Wilmington, MA
Permit No.
200
National
Tanks
Conference
& Expo
Hope to
See You in
Phoenix!
R
egistration for the 25th National Tanks Conference and Expo in Phoenix, Arizona is open. The 2015 agenda features
sessions covering a wide range of underground storage tank topics, including biofuels, remediation technologies, crucial financial responsibility issues, and the new regulations. In addition to the educational sessions, ample
opportunities for informal networking will be provided, allowing you to share knowledge and experiences with fellow
attendees.
The Expo will feature informative booths from state, tribal, and federal agencies, as well as displays from vendors
showcasing the latest tanks-related products and services. As a host city, Phoenix offers several outstanding social
opportunities, which we know will enhance your conference experience.
The conference website will be updated regularly with the latest information, so please visit often. Additionally, if
you wish to be included on the National Tanks Conference email list to receive periodic updates and reminders about
the conference, please send your email address to NTCInfo@neiwpcc.org. ■

78/August 2015

Transcription

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